Key Takeaways
- A Schätzbescheid is the Finanzamt's estimated VAT assessment under §162 AO, issued when a registered taxpayer fails to file a required return. The estimate is intentionally high to motivate filing.
- You have one month from receipt to appeal via formal Einspruch (§§ 347 ff. AO). Miss it and the estimate becomes legally final.
- Foreign Amazon sellers receive these most often, but not only, after Amazon reports their German sales to the Finanzamt under §22f UStG.
- The Einspruch does not pause the payment deadline. A separate Aussetzung der Vollziehung (§361 AO) is required to suspend collection.
- Resolving a Schätzbescheid typically costs €99 to €2,000+ depending on whether it covers one period or several years.
Information verified by Vaytax as of May 2026. Sources: Abgabenordnung (AO), UStG, BMF guidance, BVerfG 1 BvR 2237/14.
What is a Schätzbescheid?
A Schätzbescheid (estimated assessment) is a tax notice issued by the German Finanzamt under §162 Abgabenordnung (AO) when a taxpayer fails to submit a required return. The Finanzamt estimates the tax owed (usually high, deliberately, to motivate filing) and sends a binding bill. It looks like any other Bescheid: a header naming your case number (Aktenzeichen), the tax type and period (most often Umsatzsteuer, one calendar year), an estimated tax figure, a Verspätungszuschlag for late filing, statutory interest, and a payment deadline (Zahlbar bis).
The legal effect is the same as a normal assessment. It is a binding act (Verwaltungsakt) that creates a real debt. The number is not a proposal you can ignore; it is the amount the Finanzamt currently believes you owe. If you do nothing within the one-month appeal window, that number becomes legally final (bestandskräftig) and collectable.
Most Schätzbescheide arrive after escalation: one or more Mahnungen (reminders) first, then a Schätzungsankündigung (notice that an estimate is being prepared), then the Bescheid itself. By the time the letter lands on your desk, the Finanzamt has usually been trying to reach you for several months. For foreign companies without a German address, those earlier reminders sometimes never arrive, and the Schätzbescheid is the first thing the seller hears about the case.
Why foreign sellers get them
Three patterns dominate. Sellers usually recognise themselves in one of them.
1. Amazon reported your sales to the Finanzamt
Under §22f UStG, Amazon and other online marketplaces are obliged to collect VAT registration data from sellers and report seller transaction data to the German tax authorities. When a seller's data does not match a valid registration, the Finanzamt opens a case and assesses VAT for the periods Amazon reported. This is the single largest source of Schätzbescheide aimed at foreign sellers right now, almost always covering retroactive periods (typically 2022 onward). For background on the rule and how it interacts with marketplace liability, see our Amazon VAT in Germany guide.
2. You registered but stopped filing
You completed the Fragebogen zur steuerlichen Erfassung, you have a Steuernummer, and at some point the monthly UStVA filings stopped: change of accountant, change of mailing address, business pause, language confusion. The filing obligation does not stop just because the returns do. After a few missed periods, the Finanzamt issues a Schätzbescheid for each.
3. You crossed a threshold without registering
An FBA shipment landed in a German warehouse, or your B2C distance sales to Germany crossed €10,000 EU-wide, or you held inventory through a third-party logistics provider in Germany. Each of these triggers an immediate registration obligation, with no threshold for the warehouse case. When the Finanzamt later identifies the activity (often via customs filings, marketplace data, or supplier reports), the back-period VAT comes as a Schätzbescheid.
The one-month clock under §§ 347 ff. AO
The right to file an Einspruch is established by §347 AO. The deadline is set by §355 AO: one month from the date the Bescheid is deemed received. Two technical rules drive the deemed-receipt date.
- Postal delivery (Bekanntgabefiktion, §122 Abs. 2 AO). The Bescheid is presumed received three days after the postmark, regardless of when the envelope actually arrived in your mailbox. If the postmark is 14 May, the deemed-receipt date is 17 May and the appeal window runs to 17 June. If you can prove it arrived later (envelope with a later courier date, postal return receipt), the rule shifts in your favour, but the burden of proof is on you.
- Weekends and holidays do not pause the clock. If the deadline falls on a Saturday, Sunday or German public holiday, it extends to the next business day (§108(3) AO). That is the only mechanical extension.
Once the month passes, the Bescheid is bestandskräftig: legally final. At that point your options narrow dramatically. A formal Wiedereinsetzung in den vorigen Stand under §110 AO is theoretically available if you can prove you were prevented from filing on time without your own fault, but the bar is high and the Finanzamt grants it sparingly.
Your three options
Option 1: File an Einspruch (formal appeal)
The Einspruch is filed in writing or electronically with the Finanzamt that issued the Bescheid. It must name the Bescheid (Aktenzeichen + date), state that you are filing an Einspruch, and ideally give grounds. The grounds can be supplemented later; what matters is that the Einspruch itself is on file within the one-month window. Once the Einspruch is filed, the Bescheid is no longer final and the Finanzamt is obliged to re-examine the case.
Option 2: Submit the missing return
If the underlying problem is a missed UStVA, submitting the actual return is the cleanest fix. Your real numbers usually replace the estimate. Two things to know. First, the Schätzbescheid does not automatically disappear when the return is filed; you still need an Einspruch to keep the case open while the Finanzamt processes the replacement. Second, if your real VAT liability is higher than the estimate (rare but possible), filing the return makes the situation worse, not better. Get tax advice before submitting in that case.
Option 3: Pay and dispute later
Almost never the right move. Paying does not preserve appeal rights, and recovering an overpayment after the Bescheid is final requires a separate procedure (§172 AO change of an assessment) with a higher legal bar than a routine Einspruch. The only scenario where paying-and-disputing makes sense is when the amount is small and you genuinely have no grounds to appeal but want to avoid enforcement noise.
What it typically costs to resolve
Costs vary by complexity, not by total assessment amount. A single-period Schätzbescheid with clean underlying records (you have the books, the returns just were not filed) is the cheap end: €99 to €500 for a licensed Steuerberater to prepare the Einspruch, file the missing UStVA, and reconcile with the Finanzamt. Multi-year cases (common after Amazon §22f reporting that reaches back two to four years) sit at €500 to €2,000+ because each period needs a separate return reconstructed from transaction-level marketplace data.
Compare that to the cost of doing nothing. The estimated VAT itself becomes payable. Statutory interest accrues at roughly 1.8% per year (the rate the Bundestag set after the Bundesverfassungsgericht ruled the historical 6% rate unconstitutional in 1 BvR 2237/14, applicable to periods from 2019-01-01). A Verspätungszuschlag of up to 10% of the assessed tax is usually already inside the Bescheid (§152 AO). Routine collection follows: the Finanzamt can initiate enforcement against assets located in Germany. For Amazon FBA sellers, that creates real operational risk because inventory in a German warehouse is reachable.
For more on penalties and the late-filing rules around §152 AO, see our penalties and late-filing guide.
When you need a licensed Steuerberater
You can technically file an Einspruch yourself. In practice, three things make a Steuerberater the default choice for foreign sellers.
- Language and form. The Einspruch must be in German and reference the correct statutory basis. The Finanzamt will not translate or rephrase your submission.
- Service of documents. A foreign company without a German address needs a Zustellungsbevollmächtigter (authorized agent for service) under §123 AO so the Finanzamt can deliver decisions. A licensed Steuerberater fills this role as part of representation.
- Aussetzung der Vollziehung. To suspend payment during the appeal you need a separate §361 AO request, with concrete grounds and documentary support. Getting this right requires advisor judgment, not a template.
You do not need a fiscal representative in Germany. Germany is one of the EU countries that lets non-EU companies register directly through a licensed Steuerberater without that extra cost. See our explainer on fiscal representation for the distinction.
Frequently asked questions
How long do I have to appeal a Schätzbescheid?
One month from receipt under §§ 347 ff. Abgabenordnung. For postal delivery, German law presumes receipt three days after the postmark unless you can prove otherwise (§122 AO). The clock does not pause for weekends or holidays. Only if the final day itself falls on a Saturday, Sunday or German public holiday does it shift to the next business day under §108(3) AO.
What happens if I do nothing?
The estimate becomes legally final (bestandskräftig). The Finanzamt can then initiate collection action against assets located in Germany. Statutory interest (around 1.8% per year, post-2018 BVerfG ruling) accrues on the unpaid amount, and a late-filing surcharge (Verspätungszuschlag, §152 AO) typically already sits inside the Schätzbescheid itself.
Can I just submit the missing return and ignore the Schätzbescheid?
Submitting the actual return usually causes the Finanzamt to replace the estimate with your real numbers, but you still need to file a formal Einspruch within the one-month window to keep the case open. Filing the return alone does not preserve appeal rights if the deadline passes.
My company is not in Germany. Can I appeal myself?
Legally yes, but the Einspruch must be in German and reference the correct statutory basis. A foreign company without a German address also needs a Zustellungsbevollmächtigter (authorized agent for service) under §123 AO for the Finanzamt to deliver decisions. In practice, a licensed German Steuerberater handles both.
Will the appeal stop the payment deadline?
No, not automatically. The Schätzbescheid remains payable while the appeal is pending. To suspend payment, you file a separate Antrag auf Aussetzung der Vollziehung (§361 AO request to suspend enforcement) alongside the Einspruch.
How much does it cost to resolve a Schätzbescheid?
For a single-period assessment with clean records, a professional response typically costs €99 to €500. Multi-year retroactive cases (common after Amazon §22f reporting that goes back two to four years) range from €500 to €2,000 or more, depending on the volume of returns to reconstruct.
What if Amazon reported my sales but the numbers are wrong?
Common. Amazon's transaction-level reports under §22f UStG include shipments to other EU countries that are not German-taxable, plus B2B reverse-charge transactions that should not be in the German VAT base. The Einspruch substantiates the correct German-taxable portion using your transaction-level Amazon reports.